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;-''''OU DE"T & T";" "AG^ i:J r.t1 wi 1..1 ~ r wl\j\i lL [F8il 9.22' 00 16:50/ST. 16:42/NO. 486J20141~ Mayor and City Council Members City of Roseville Seprember22,2000 Page 3 lli. Absence of Operating Conditions. It is particularly striking that the Staff Report for this project contains almost no conditions which would limit or regulate the operation of this gambling facility. While the Staff Recommendation does include a limitation on hours (originally limited to 1] p.m. but now 12:45 a.m., a twenty-four hour use under Section 1234 of the City Code) there are no other operating conditions or limitations. For example, there is absolutely no restriction on the number of seats which the developer may locate within the facility, or the specific gambling activities or concessions permitted. In contrast, Chapter 303 of the City Code which regulates amusement game rooms, lists a significant number of requirements for any conditional use permit for such similar operations, including insurance. security, traffic management, indoor and outdoor pedestrian plans, onsite manager. etc. Because the proposed gambling operation i!; the samc or very similar to the types of uses regulated by Chapter 303, more serious consideration should be given to imposing restrictions similar to those delineated in Section 303.08. The complete absence of any sueh operating restrictions suggests that additional staff analysis should be undertaken before this proposal can be thoughtfully considered by either the Planning Commission or the City Council, or for that matter, by the community as a whole. As an aside, the September 25 Staff Report mentiOJ:ls (paragraph 3.7) that the parking lot should be screened from adjoining residential areas, to satisfy the 24-hour operation requirements of Section 1234, but then fails to in,clude this requirement as one of the fonnal CUP conditions. This oversight should be corrected. IV. Failure to Satisfy Conditional Use Criteria. As quoted in tlle StaffRepo~ Section 1013 of the City Code identifies six factors which should be considered in assessing an application for a conditional use pennit. To date, the analysis of those factors seems cursory, and has neglected to consider substantial evidence that would argue against approval of this proposal. For example. the traffic analysis prepared by the Staff, claims that traffic will "increase" with the addition of the bingo hall by 500 - 600 cars per day, but no consideration has been given to the fact that traffic for this operation is likely to be concentrated at the beginning and ending of each gambling session. This is in sharp conn-ast to the traffic in a typical retail center. which is evenly spread over the course of time when a retail center is open for business. Correspondence to you dated September 21,2000 from the owner of the adjoining office building (copy #3 enclosed) raises this same concern. Without any limit on the number of seats or the types of concessions and gambling operation,s, the Staff" s traffic volume estimate provided to date may not be reliable. An in-depth traffic study should be required given the substantial volume and concentrated timing of the traffic generated by this proposal. _ 11IIiI~ "rrl'Ti1t7""